SAFETY REPORTS

n
n

Reg 4
Every operator shall take all measures
necessary to prevent major accidents
and limit their consequences to persons
and the environment

SAFETY REPORTS
n

Reg 7(7)
n

The operator shall send to the CA a report

containing information which is sufficient
for the purposes specified in Part 1
Schedule 4 and comprising at least the
information specified in part 2 of that
Schedule

Schedule 4-Purpose and Contents

of Safety Report
n

Part1-The purposes referred to in Reg7

are as follows:
2. Demonstrating that major accidents
hazards have been identified and that
the necessary measures have been
taken to prevent such accidents and to
limit their consequencesfor persons and
the environment.

Schedule 4 -Part 2
Minimum Information to be included in a
Safety Report

Identification and accidental risk analysis

and prevention methods:
n detailed description of the possible
major accident scenarios
n and their probability ----------Bang!

Schedule 4 -Part 2
Minimum Information to be included in
a Safety Report
n

Identification and accidental risk

analysis and prevention methods:
n

Existing Guidance
n

4(b)assessment of the extent and severity

of the consequences of identified major
accidents
n

(R2P2 p76)

Population

HSE has produced a suite of guidance

documents concerning ALARP. These
are designed to give high level
principles which D/Ds can then use to
promulgate sector specific advice.
The documents are:
Reducing Risk, Protecting People
(R2P2);

ABC Chem Tank

ALARP in COMAH

Existing Guidance (continued)

n

For practical purposes:

n All Measures Necessary
(AMN)=SFAIRP=ALARP
n

Principles and guidelines to assist HSE in its

judgments that duty-holders have reduced
risk as low as reasonably practicable;
Assessing compliance with the law in
individual cases and the use of good practice;
and
ALARP in Design - Policy and Guidance.

ALARP Demonstration

Relationship between R2P2 and the

ALARP Suite

"Reducing Risks, Protecting People"

informs *

'ALARP

'R2P2'

Principles and
Guidelines'

informs **
HSE's
expectation
e.g. TOR
framework,
primacy of
Good
Practice,
tolerability
criteria

Information
to Stakeholders

'Good
Practice'

'Design'

legal commentary
+ policy

D/Ds'
Guidance

Guidance
to Staff

HSE's expectation/enforcement policy

* Annex 3 of R2P2 reflects the ALARP guidance

** e.g. the concept of 'hypothetical person' set out in R2P2 is adopted in the ALARP guidance

".... suitable controls must be in place

place to
to
address all significant
significant hazards
hazards ....
.... and
and
those controls, at a minimum, must
implement authoritative good practice
practice
irrespective of situation-based risk
estimates ...."
...."
"authoritative
"authoritative good
good practice"
practice" =
prescriptive legislation, ACOPs,
guidance
guidance produced
produced by
by government.
government.

ALARP Demonstration

Increasing Individual
and societal concerns

HSE framework for the tolerability

of risk

Unacceptable Region
Tolerable Region
Broadly Acceptable Region

"Reducing Risks, Protecting People"

".... both individual risks and societal
concerns ....
.... must
must be
be taken
taken into
into account
account in
deciding whether a risk is unacceptable,
tolerable or broadly acceptable
acceptable ...."
...."
"individual risks also give rise to societal
concerns and the latter
latter often
often play
play aa far
far
greater role in deciding whether risk is
unacceptable or not."

ALARP Diagram

A L A R P P rin c iple

Unacceptable region
Level of risk cannot be justified except in extraordinary circumstances.

M e aa ssuurreess ttoo rreed

du c e r i s k
m u s t b e t a k e n u n t il th e r i s k i s
b r o a d ly acceptable (BA) or
u n til th e c o s t o f f u r t h e r r i s k
reduction wou
u lld
d b e g r o s s ly
d i s p r o p o r t i o n a t e ( G D ) t o tth
hee
reduction in risk that w o u ld
be achieved.

Solicitor`s guidance
"We believe it is right that, in all
cases, the judgment as to
whether measures are grossly
disproportionate should reflect
societal risk, that is to say, large
numbers of people (employees
or the public) being killed at one
go. "

___________________________________________________
Tolerable region
If the risks fall in this region then a CASE SPECIFIC ALARPdemonstration
is required. The extent of the demonstration should be proportionate
to the level of risk
____________________________________________________

Broadly acceptable region

Level of residual risk is regarded as insignificant and further effort
to reduce risk not likely to be required. ALARP demonstration based upon
adherence to codes, standards and established good practice. These must
be shown to be up to date and relevant to the operations in question.

Case Specific ALARP

demonstration
Operator has to answer the
following fundamental
question:

"What more can I do

to reduce the risks "?

Case Specific ALARP

demonstration

Proportionate Risk Assessment

Also:

The depth of the analysis in the

operators report should be
proportionate to

"Why have I not done

it"?

a) the nature and scale of the

MAHs
b) the risks posed to
neighbouring populations

BLEVE

if the measure appears

reasonable and it cannot be
shown that the cost of the
measure is grossly
disproportionate to the benefit to
be gained, then the Operator is
duty bound to implement
implement that
measure

ALARP Demonstration

Risk estimation
Selection of a representative
set of events

Estimation of consequences and frequency

for each event
Ranking & screening (e.g risk matrix, fn
curves)

Risk Matrix (Illustrative)

But the higher the installation lies on the

societal concerns scale the greater the need
to look for additional measures, over and
above the normal standards.
How to approach?
n
n

1. Identify risk reduction measures.

2. Assess using Lines Of Defence analysis with
cost estimates
3. Possibly, in extreme cases, add a Cost Benefit
Analysis.

Proportionality: Type of ALARP Demo.

Risk reduction
regardless of cost

Intolerable

Likely >10-2
Intolerable

Intolerable

Intolerable

Intolerable

Intolerable

Relevant Good Practice

Plus
Unlikely
10-4-10-2

TIFALARP(Int
olerable if
Fatality >10-3)

TIFALARP(Int
olerable if
Fatality >10-3)

Intolerable

Intolerable

Intolerable

Risk reduction
Measures
Plus

Very Unlikely

TIFALARP

TIFALARP

TIFALARP/Int
olerable

TIFALARP/Int
olerable

Intolerable

TIFALARP/Br
oadly
Acceptable?

TIFALARP

TIFALARP

50-100 Fatalities

100+ Fatalities

Tolerable if ALARP

Gross
Disproportion

10-6-10-4

Remote
10-6-10-8

Broadly
Acceptable

Single Fatality

Broadly
Acceptable

2-10 Fatalities

11-50 Fatalities

Relevant Good
Practice
Broadly Acceptable

`So what`

Sensitivity and uncertainty

analysis
Would being more thorough be
worthwhile?
Uncertainties in models, data,
methodology.
Cautious best-estimate basis.
basis.
Adopt Precautionary Approach
p89
p89 91R2P2
91R2P2

Purpose of SR is to demonstrate
ANMs (ALARP) from an activity
(`risk from what`)
Four combinations (`risk of what`
and `risk to what`):
1 IR to those on-site
2 IR to those off-site
3 SR to those on-site
4 SR to those off-site

If all the risks are BA then

compliance with good practice
demonstrates ALARP
Otherwise the events that
contribute significantly to the
risks need to be identified, risk
reduction options compiled,and
appropriate decision aids used
(eg LOPA for simple cases
CBA for more difficult ones)

If AMNs are in place for each

major accident scenario then
there is nothing more that can be
done and professional judgement
will suffice.
`Explicit` detailed quantification of
risks is not necessary unless the
proportionality is high